This Privacy Policy explains how we collect, use, store, share and protect your personal information. It applies to all JPay websites (“the Site”), applications, services, products and tools (collectively “our Services” each a “Service”) regardless of how you access or use them. However, the privacy of all interactions with inmates, including the use of our Services, is ultimately governed by the rules and regulations set by the applicable correctional facility.

We may offer you the ability to access our Services using a mobile device, either through a mobile application or via a mobile optimized or non-optimized website. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices. This Privacy Policy will be referenced by all such mobile applications or mobile optimized websites. By using our Services, and/or registering for a JPay account, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy and in any of our Terms of Service to which you agree.

1. Collection of Your Information

We collect two (2) types of information about you through our Services: (1) information you provide to us while using our Services (described below under “Information You Provide to Us”) and (2) information collected automatically as a result of your use of our Services (described below under “Information Collected Automatically”).

Information You Provide to Us

You may choose voluntarily to provide certain personal information to us depending on which of our Services you use. This information may include:

• Contact information for yourself or others that you provide such as: name, address, telephone number or email address;

• Contact information for yourself or others that you provide such as: name, address, telephone number or email address;

• Credit/Debit card information or any card information used for transactional purposes;

• Correspondence with customer support such as email, regular mail and conversations over the phone; and

• Information and comments you post on a blog, forum, or social media site associated with our Services.

Information Collected Automatically

Like most web-based services, we (or our service providers) may automatically collect information from your browser or your device when you use our Services. For example, this could include the frequency and duration of your visits to the Site (similar to TV ratings that indicate how many people watched a particular show). We do not combine automatically-collected information with personal information. If ever in the future we do combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Notice.

Cookies and Other Information

Like many websites, we use cookies and other tracking tools for a variety of purposes, including to improve your visits to this Site. Cookies are pieces of information that are transferred to the hard drive on your computer or other electronic device for record-keeping purposes. These cookies or similar technologies may identify your browser, device, Internet Protocol (IP) address, unique device identifier, device attributes, location, and language. Ultimately, these cookies and similar technologies allow websites to remember important information that will make your use of the website more convenient.

Like many websites, JPay uses these technologies to analyze trends, gather demographic information about our user base, track your movements around the Site, see how much time you spend on the Site, administer the Site, tailor the Site for you, and to help the Site work better for you – for example, by remembering your preferences.

You may configure the options available in your web browser settings to notify you when you receive a cookie or you may change your cookie preferences in your internet browser or with third parties. You can control and/or delete cookies used by our Site at any time. For instructions on how to delete cookies using your particular internet browser, visit www.aboutcookies.org . You can delete all existing cookies on your computer and adjust settings for most browsers to prevent cookies from being received. Like most websites, if you disable cookies, some content may not function properly. However, you may still use JPay by contacting Customer Service.

Our Site may use third party cookies and tools from Facebook, Twitter, DoubleClick, and Google Analytics.

Advertising Alliances Opt-out

In addition to adjusting the appropriate settings in your browser, many advertising companies that may collect anonymous information for targeted advertising purposes are also members of the Digital Advertising Alliance or the Network Advertising Initiative. Both of these organizations provide directions on how individuals can opt-out from targeted advertising by their members. You can find more information on these opt-out capabilities at www.aboutads.info and www.networkadvertising.org.

How We Respond To Do Not Track Signals

Currently, various browsers—including Internet Explorer, Firefox, and Safari —offer a “Do Not Track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites visited by the user about the user’s browser DNT preference setting. Please note that at this time we do not honor “DNT” signals or other mechanisms that may allow you to opt-out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to DNT signals that we would describe in this notice in the future. For more information on DNT, please visit www.allaboutdnt.org.

2. Use of Your Information

In general, JPay collects and uses your information to provide the Service(s) you have requested. We use your personal information in the following ways:

• to facilitate the creation of and secure your JPay account on our network;

• to identify you as a user in our system and to otherwise administer and operate our Services;

• to improve the quality of experience when you interact with our Services;

• to send you administrative email notifications, such as security or support and maintenance advisories;

• to deliver customized or personalized content, information, or advertising;

• to respond to your inquiries and other requests; and

• to send newsletters, surveys, offers, and other promotional materials related to our Services or on behalf of third parties and to monitor the effectiveness of our marketing programs.

3. Disclosure of Your Information

We disclose your information as described below and as described elsewhere in this policy.

• Third Parties Designated by You. When you use our Services, the personal information you provide will be shared with third parties that you designate to receive such information. For example, you may elect to communicate with an inmate, which requires the disclosure of certain aspects of your information to them.

• Third Party Service Providers. We may share your personal information with third party service providers in order to: provide you our Services; to conduct quality assurance testing; to facilitate the creation of accounts; to provide account authentication and user verification services; and to provide technical support. This may include, but is not limited to, credit/debit card authorization and fraud screening services, credit card processors, and banking authorities. Any third parties are required to adhere to the same level of security and privacy controls as JPay.

• Affiliates. We may share some or all of your personal information with our parent company or companies, subsidiaries, joint ventures and other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this notice.

• Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset.

• Other Disclosures. Regardless of the choices you make regarding your personal information (as described below), JPay may disclose personal information, if it believes in good faith that such disclosure is necessary as follows: (a) to comply with relevant laws or to respond to subpoenas or warrants served on JPay; (b) in connection with any legal investigation; (c) to protect or defend the rights or property of JPay or users of our Services; (d) to investigate or assist in preventing any violation or potential violation of law, this notice, or our Terms of Use; and/or (e) if we believe that an emergency involving the danger of death or serious physical injury to any person requires or justifies disclosure of information.

• Disclosures Via Blogs, Forums, Or Social Media Websites. If you make any comments on a blog, forum, or social media website associated with our Site, you should be aware that any personal information you submit there can be read, collected, or used by other users of the forums, and could be used to send you unsolicited messages. We are not responsible for the personal information that you choose to submit in these blogs, forums, or social media websites.

4. Security and Retention of Your Information

• We store and process your information on computers, in facilities, and in servers, which may be located inside or outside of the US.

• We use reasonable administrative, technical, and physical safeguards designed to reduce the risks of loss, interception, misuse, unauthorized access, disclosure and/or alteration of your information. Some of the security safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

• We make concerted good faith efforts to maintain the security of your information. Although we work hard to ensure the integrity and security of our systems, please note that no information system can be 100% secure, and we cannot guarantee the security of that information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time.

• We abide by all local and national laws with regard to the use of information, and expressly prohibit use of said information for any illegal or otherwise inappropriate conduct.

• Additionally, we will keep your information for only as long as it is needed to carry out our mission or meet legal obligations. If your information is no longer needed, we will destroy it quickly and responsibly. And as a reminder, our Terms of Service state that inmates lose access to all data upon their release.

• All users with a JPay account may make any changes to their account information and contact preferences at any time by logging into their account and going to the ‘My Account’ page.

5. Marketing

• We do not sell or rent your personal information to third parties.

• We may call, text, mail or email you with helpful information, updates or promotional offers.

• We may use third party suppliers to market to you. Pixel tags and cookies may be used in digital messaging and on our website to help us measure effectiveness, site usage, and to enable us to provide more focused and subsequent marketing communications to you.

• You can opt-out of receiving marketing communications from us at any time by contacting Customer Service at support@jpay.com.

• From time to time, JPay may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Due to the fact that this information is important to your communication and involvement with JPay, you may not opt-out of receiving these forms of communications.

6. Children’s Privacy

JPay, its related sites, applications, services and tools are for general audiences and are not intended for children under the age of thirteen (13). We do not knowingly collect personal information from users in this age group from any source. If we become aware that a child under 13 has provided us with personal information through our Services, then we will delete this information from our files. If you are the parent or legal guardian of a child under 13 who you believe has provided personal information to JPay through our Services, please contact our Information Privacy team at the following e-mail address: privacyteam@jpay.com.

7. Compliance with Other Laws

In order to comply with the Financial Modernization Act of 1999, also known as the Gramm-Leach-Bliley Act, JPay maintains a customer privacy program designed to ensure the security, integrity, and confidentiality of non-public customer information.

Moreover, JPay ensures compliance with US Government regulations implementing the Unlawful Internet Gambling Enforcement Act (UIGEA). UIGEA prohibits businesses from processing restricted transactions. A restricted transaction involves knowingly accepting a transmittal of any credit, funds, instrument, or proceeds in connection with the participation of another person in unlawful internet gambling. In the event that JPay receives knowledge that a customer is engaged in illegal internet gambling, JPay will close the customer’s account and cancel all transactions.

8. External Links

JPay, any related sites or its mobile apps may contain links to other sites and if you decide to follow those links, JPay will not be responsible for the privacy practices or the content of those websites.

9. Changes to this Privacy Policy

We may amend this Privacy Policy at any time by posting a revised version on our website(s) and mobile apps. The revised version will be effective at the time we post it.

10. Conditions of Use, Notices, and Revisions

If you choose to use JPay’s related sites, applications, services and/or tools, your use thereof and any dispute over privacy is subject to terms and conditions outlined in this Privacy Policy and in our Terms of Use, including limitations on damages, resolution disputes, and application of the law of the state of Florida.

11. California and Vermont Privacy Rights

If you are a California or Vermont resident who has provided personal information to a business with whom you have established a business relationship for personal, family, or household purposes (“California or Vermont customer”), you are entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California or Vermont customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.

However, under the law, a business is not required to provide the above-described lists, if the business adopts and discloses to the public (in its Privacy Policy or Notice) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the business gives users a mechanism to opt-out of having their personal information disclosed to third parties for their direct marketing purposes. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost-free means to exercise the right.

We have opted for this alternative approach. As stated in this notice, we give customers a mechanism to opt-out of having their personal information disclosed to third parties for their direct marketing purposes. Therefore, we are not required to maintain or disclose a list of third parties that received your personal information for marketing purposes. If you wish to opt-out of sharing your personal information with third parties for their direct marketing purposes, please send an email to privacyteam@jpay.com.

12. Your Options

• If you no longer wish to receive marketing communications from us, email Customer Service at support@jpay.com. However, we still may contact you regarding any transactional or legal matter.

• If you no longer wish to use our services, email our Customer Service at support@jpay.com.

• If you have questions about this Privacy Policy, JPay’s information practices, Terms of Service, or your dealings with JPay, write us at: privacyteam@jpay.com.